Debra J. Jezouit

Partner

[email protected]

Washington, D.C.

P: +1.202.639.7728
F: +1.202.585.1032
Debra Jezouit Photo

Debra Jezouit is a partner in the Environmental, Safety, & Incident Response Practice Group in the Washington office. She is widely recognized for her experience in Clean Air Act and Climate Change issues, representing clients in multiple industries, including electric generating companies, cement manufacturers, iron and steel foundries, pharmaceutical companies and chemical companies. She handles such matters as New Source Review and New Source Performance Standard compliance counseling, applicability determinations and enforcement, counseling on hazardous air pollutant requirements, acid rain compliance, emissions monitoring issues, air permitting at the state and federal level, the development of and compliance with emissions trading programs, and emerging issues including environmental justice and Civil Rights Act Title VI complaints.

Ms. Jezouit participated extensively in the regulatory development process for the Clean Air Act's Acid Rain Program and led negotiations with the U.S. Environmental Protection Agency on the development of various revisions to acid rain regulations. She has worked with the EPA on other air emissions trading programs, standards for air toxic emissions for several industrial categories, New Source Review rule reform, revisions to the New Source Performance Standards for electric generating units and Portland cement plants, and existing source performance standards for greenhouse gas emissions from electric generating units as well as several other rulemakings related to Clean Air Act programs. Ms. Jezouit has managed internal audits for several clients to evaluate their compliance with various Clean Air Act programs, including greenhouse gas reporting requirements, National Emissions Standards for Hazardous Air Pollutants, and ozone depleting substances requirements, and she has assisted clients both to establish and periodically revise their internal procedures for analyzing New Source Review applicability. In addition, she has written and spoken extensively on New Source Review issues, including conducting New Source Review workshops for various clients. She also has extensive experience in responding to EPA investigations of alleged Clean Air Act violations and has negotiated several settlements of alleged Clean Air Act violations at the state and federal level, as well as with environmental groups.

Related Experience

  • Major electric generating company – representation on development of state Regional Haze and Affordable Clean Energy Act plans
  • Major electric generating company – advice on compliance with the Cross State Air Pollution Rule
  • Portland cement companies – representation in development of comments on National Emissions Standards for Hazardous Air Pollutants for the Portland cement industry, and subsequent appeals of final rules, which resulted in more reasonable air toxics standards for the industry and an extension of the compliance deadline by two years (Portland Cement Association v. EPA (D.C. Cir. 2011) and Natural Resources Defense Council v. EPA (D.C. Cir. 2014))
  • U.S. v. Holcim (US) Inc. (D.Md) – represented Holcim (US) Inc. in an enforcement suit brought by EPA for alleged Prevention of Significant Deterioration requirements under the Clean Air Act and negotiated a favorable settlement of the case for the client prior to trial
  • Sierra Club v. The Dayton Power and Light Company, et. al (S.D. Ohio) – represented three co-owners of a power plant on alleged violations of the Prevention of Significant Deterioration, New Source Performance Standards and opacity requirements of the Clean Air Act and successfully negotiated a settlement of the case prior to trial
  • Reliant Energy – representation in New Jersey v. Reliant Energy Mid-Atlantic Power Holdings, et. al (E.D. Pa), regarding alleged violations of the Prevention of Significant Deterioration and Title V permitting requirements of the Clean Air Act
  • Major pharmaceutical company – negotiated settlements of potential Clean Air Act violations at several facilities that were discovered as a result of internal audits and during an EPA investigation
  • Major electric generating company – negotiated settlement of Clean Air Act violations alleged by environmental groups and represented company in district court to obtain approval of the settlement in face of opposition to settlement terms by third parties
  • Electric generating company – counsel on controversial air permit for a new source and development of strategy for addressing community opposition
  • Portland cement company – negotiated settlement of alleged NESHAP and NSPS violations and negotiated Title V permit terms
  • Electric generating company – representation on Civil Rights Act Title VI complaint
  • Class of ‘85 Regulatory Response Group – representation of a large coalition of electric generating companies regarding issues arising under the Clean Air Act and other environmental statutes, including development of comments on various EPA rulemakings and providing analyses of regulations and court decisions affecting the industry
  • Electric generating company – Representation before the U.S. Court of Appeals for the Third Circuit in an appeal of an EPA order regarding the company's Title V permit
  • Electric generating companies – Design and assist in implementation of New Source Review, NSPS, NESHAP, and refrigerants compliance programs for fossil-fuel fired power plants

Awards & Community

Listed in Chambers USA, 2011-2022

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What's Next on Air Toxics

Speeches & Presentations

Air & Waste Management Association's Electric Power Transformation: 2021 MEGA Symposium on Policies and Technologies for Clean, Reliable, and Cost-effective Energy

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